On Thursday, July 1, 2021, the Federal Emergency Management Agency (FEMA) announced the selection the subapplications for the $700 million being made available in fiscal year 2020 (FY20) for Building Resilient Infrastructure and Communities (BRIC) and Flood Mitigation Assistance (FMA) grant programs. These competitive programs provide funding to states, tribes, territories, and local governments for eligible mitigation activities – ultimately aimed at reducing disaster losses and protecting life and property from disaster-related damages.
In its inaugural funding cycle alone, BRIC increased the nation’s investment in pre-disaster mitigation to $500 million and the individual project cap to $50 million – a dramatic increase from the $4 million cap for mitigation projects and $10 million cap for resilient infrastructure projects under the PDM program. BRIC, unlike its predecessor, the legacy FEMA Pre-Disaster Mitigation (PDM) program, provides more meaningful and significant funding opportunities for high-impact infrastructure and community-based projects.
In total, 22 BRIC projects were competitively selected this cycle and the projects chosen are from nine states plus the District of Columbia (D.C.), totaling $377.7 billion. Hagerty assisted several applicants and subapplicants with their BRIC projects in FY20, ultimately helping submit nearly $1 billion of BRIC subapplications for FEMA review. Based on this experience, below are some of our key takeaways and lessons learned from BRIC this year as well as recommendations that are applicable during the next funding cycle.
Key Takeaways
The Success of Climate and Code Adoption
In the era of climate change, we should be pleased that 18 of the 22 competitive BRIC projects selected by FEMA included nature-based solutions into their mitigation projects. In fact, nature-based solutions, part of the technical scoring criteria, appears to be one of if not the most influential factor in project selection.
Second to nature-based mitigation, the competitive projects selected are from Applicants that have adopted the 2015 or 2018 versions of the International Building Code and the International Residential Code. Most, but not all, of the Applicant localities have a Building Code Effectiveness Grading Schedule (BCEGS) rating at or below 5, likely indicating that the chosen subapplicants have a similar BCEGS ratings; however subapplicant BCEGS rating are confidential. In the technical scoring criteria, subapplicants could receive up to 35 points for robust code adoption measures; accordingly, those with stronger building codes excelled during the selection process.
Small, Impoverished Communities
Additionally, we know BRIC funding is on the rise with the hope of providing greater support to small, impoverished communities. Last May, FEMA announced that $1 billion will be made competitively available under the BRIC program in 2021, with 40 percent being dedicated to supporting small, impoverished communities. Notably, this cycle, only two competitive projects selected by FEMA were designated as small, impoverished communities. The funding for these two projects totals approximately $24.7 million, or 7%, of the $377.7 million competitively available.
What Comes Next?
All BRIC applications and associated projects were adjudicated into three categories: selected for further review, not selected, or did not meet Hazard Mitigation Assistance (HMA) requirements (ineligible). Wondering what this means and what to do next?
Selected for further review
Competitive mitigation projects, selected for further review, will likely be notified about the upcoming grant award once FEMA has completed the associated and required Environmental and Historic Preservation (EHP) review. Depending on the FEMA Region, EHP review and project approval can often be a lengthy process.
Not selected
Subapplicants with projects that were not selected should consider resubmitting in the next BRIC funding round or in the next available Hazard Mitigation Grant Program (HMGP) funding opportunity. If the project did not include green infrastructure or nature-based mitigation, subapplicants should evaluate if these features can be added to the project’s scope. It is sensible to assume that nature-based mitigation will be critical again in next year’s BRIC selection process.
Did not meet HMA requirements (ineligible)
If the project was deemed ineligible, subapplicants can contact their State Hazard Mitigation Officer (SHMO) and request the project’s National Technical Review (NTR) memo. This memo will assist in highlighting the eligibility, feasibility, and cost-effectiveness issues identified by the NTR and FEMA. Based on the memo’s findings, subapplicants can decide if the project can be fixed and resubmitted in the BRIC 2021 cycle.
BRIC 2021 and Beyond
The BRIC 2021 Notice of Funding Opportunity (NOFO) will likely be out next month and, given the tight turnaround, it is unlikely that many components of the program will change drastically. As applicants and subapplicants continue to scope potential projects for BRIC 2021, they should consider the following to best position projects for success.
- Eligibility, feasibility, and cost-effectiveness. Eligible, feasible, and cost-effective projects are a recipe for HMA success and should not be deemed ineligible by FEMA.
- Focus on nature-based solutions. Submit projects that have, at a minimum, a green/gray nexus or components of nature-based mitigation features. More information on how to incorporate these features can be found here.
- Maximize the technical and qualitative scoring rubrics. This will help ensure that your project is competitive.
- Give your project a descriptive title. This is the first thing a reviewer likely reads and encourages them to take a deeper dive.
- Obtain and analyze your BCEGS rating. If your current BCEGS rating is over a 5, contact ISO to determine ways to lower the rating.
- Establish public-private partnerships. These can help provide an increased local share match making your project potentially more favorable upon review.
- Consider project phasing. Submitting the most credible project possible is important; therefore, if your project is in a preliminary design phase, consider submitting a phased project proposal. 12 phased projects were selected in BRIC 2020.
- Advocate for your local jurisdiction. If your local jurisdiction has adopted the 2015/2018 IBC/IRC code and the State has not, reach out to your SHMO and/or FEMA Region to discuss if an exception can be given and the 20 points can be awarded for your subapplicant project(s).
Additionally, FEMA just announced their 2021 BRIC and FMA Program Webinar Series which begins on July 28 and will continue throughout October. During these sessions, FEMA will bring subject-matter experts and partners together to provide technical information, best practices, tools, and resources regarding these grant programs. The webinars are designed for leaders in states, local communities, tribes, and territories, as well as private sector entities, private non-profit organizations, and individuals interested in learning more about the BRIC and FMA grant programs and strategies for how to apply for them. All sessions will be recorded and posted to FEMA’s YouTube channel.
Conclusion
While this year’s BRIC competitive grant funding selections were limited to nine states and D.C., we need to remember it was the inaugural grant cycle for this promising funding stream. All that worked in support of BRIC projects – FEMA, States, tribes, subapplicants, and mitigation practitioners alike – learned valuable lessons during the process. Now, it is important to harness those lessons learned to include creating a more equitable approach to improve the resilience of communities. As we face the impacts of climate change and acknowledge that climate change is disproportionately impacting underserved communities, we need to ensure that moving forward, this critical funding stream is obtainable for all.
Hagerty Can Help
While the cost share for this program is 75 percent federal and 25 percent non-federal, FEMA will provide 100 percent federal funding for management costs associated with the administration of a BRIC-awarded mitigation measure or project. Therefore, our professionals can help at little-to-no additional cost. Hagerty’s Mitigation Team are experts in navigating the pre- and post-disaster funding world. We are available to talk about your recovery needs, including how to access all funding available through federal grant programs. To learn more, please fill out the form below.
Amelia Muccio is the Director of Mitigation at Hagerty Consulting and a subject matter expert in disaster recovery. With over 15 years of experience in public health, disaster preparedness, mitigation, and financial recovery, Amelia has helped clients obtain $5 billion in federal funds after major disasters, including Hurricane Sandy, the California Wildfires, and Hurricane Harvey.
Want to know more about the BRIC program?
Please fill out the form below and one of our mitigation experts will be in touch!